Privacy Policy

Last updated: October 20, 2026

Welcome to Chubkins! We're glad you're here.

1. INTRODUCTION #

PETOSKEY GAMING COMPANY, LLC ("Petoskey," "we," "us," and "our") respects your privacy and we are committed to protecting it through our compliance with this privacy policy (the "Privacy Policy"). The term "you" refers to the person visiting the Chubkins website or using the Chubkins mobile application (collectively, the "App").

This Privacy Policy describes the types of information we may collect from you or that you may provide when you use the App, and our practices for collecting, using, maintaining and organizing, protecting, deleting and disclosing that information (collectively, "process" information).

Some of this information may be considered "personal information" or "personal data" under applicable law, which is information that is about any individual, or from which any individual is identifiable ("personal information").

Chubkins is not offered in every country. Section 12 describes additional rights for residents of certain U.S. states.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use the App. By accessing or using the App, you agree to this Privacy Policy.

2. PERSONS UNDER THE AGE OF 18 #

2.1 Minimum Age #

The Service is not intended for individuals under 16 years of age. Users must be at least 18 years old, or between 16 and 18 years old with parental consent, to use the Service. Petoskey does not knowingly collect personal information from children under 16. Redeeming diamonds for gift cards is only available to players who are 18 or older, or the age of majority where they live if that is higher (see Section 3.1, "Redemption Information").

If we learn that we have inadvertently collected information from a child under 16, we will delete that information. If you believe we may have collected information from a child under 16, please contact us at privacy@chubkins.app.

2.2 Note to Parents and Guardians #

Because it is difficult for us to verify a person's age online, it is entirely YOUR responsibility to supervise your child's online activities at all times. Parental control tools like filtering software and hardware are commercially available to help you limit a child's access to potentially harmful material on the Internet.

If you discover that your child or any other minor has obtained an Account on the Service without a parent or guardian approval, please contact us immediately via email at privacy@chubkins.app.

3. TYPE OF INFORMATION WE COLLECT AND HOW IT MAY BE USED #

3.1 What Personal Information Do We Collect?#

We collect personal information that you provide directly to us, such as when you create or update your account, adjust your email or notification preferences, chat with a co-parent, redeem diamonds for a gift card, participate in surveys or events, submit feedback, or contact us for customer support.

We also collect certain technical information automatically when you access or use the App. This information helps us operate, maintain, and improve Chubkins and includes standard details about your device, connection, and usage activity.

The categories of information we collect, and their sources, include:

Personal and Authentication Information #

We collect identity data that you provide to us when creating and accessing a Chubkins account. You can play as a guest, or sign in with a one-time code sent to your email address, with Google, or with Apple. Depending on how you sign in, we collect your email address and the account identifier that Google or Apple shares with us. We also collect the display name you choose, an optional profile photo, and a record of when you agreed to our Terms of Use and this Privacy Policy and which version you agreed to. The purpose of collecting this information is to create and manage your Chubkins account, authenticate users, provide access to services, and secure your account.

Information Other Players Can See #

Your display name, profile photo and Chubkins are visible to your co-parents, and may appear to other players on leaderboards and the profiles they open. Other players can report a name, photo or Chubkin that breaks our Community Standards.

Device Details #

We collect device type and model, operating system and version, browser type and settings, IP addresses, unique identifiers (such as the Android ID, the advertising identifier (the Google Advertising ID on Android or the IDFA on iOS), the identifier for vendor (IDFV) on iOS), language and time zone settings, the mobile carrier on Android, the push notification token, dates and times of connection, and other technical communication. This information is used to ensure platform compatibility, optimize user experience, enhance security, detect fraudulent activity, and analyze technical issues for service improvements.

Approximate Location #

We use the IP address of each sign-in to determine the country you are in, using the vpnapi.io service. We use your country to show the gift cards available there and to restrict access and redemption where Chubkins is not offered. We do not ask for GPS or precise location permission.

Gameplay and Usage Details #

We collect records of your use of the App and our website, including sessions, progression, missions, items and in-game currency earned and spent, page views, clicked pages or links, content interactions, and communication preferences. This data is linked to your account ID rather than to your name or email address. It is pseudonymized, not anonymized, so it is still personal information. This data helps us operate the game, improve App and website functionality, personalize content, analyze engagement trends, and tailor our services to user needs.

Chat Messages and Photos #

If you chat with a co-parent, we store the messages and photos you send and when you sent them. Messages are checked automatically for banned words and contact details, and our team reviews any messages that are reported. Message notifications sent to your co-parent include your display name and the message text.

Contacts #

If you choose to invite someone by text message, the App asks for permission to read your contacts so you can pick who to invite. The names and phone numbers in your contacts stay on your device. We do not send them to our servers or to analytics providers.

Camera and Photo Library #

If you take or choose a photo for your profile or a chat, the App asks for permission to use your camera or photo library and uploads only the photo you select.

Payment Details #

We do not directly collect or store your payment information such as credit card numbers, cardholder names, card security details, or card expiry dates. When you make purchases, these transactions are processed through the Apple App Store or the Google Play Store, which handle all payment details according to their own privacy policies. We may receive confirmation of completed transactions, including the product, price, currency and store transaction identifiers, but we do not have access to your complete payment information.

Redemption Information #

Before your first redemption, the App asks for your date of birth to confirm you are old enough to redeem. You enter it once and cannot change it later. To deliver a gift card, we collect the email address the card should be sent to, the card you chose and its value, and the diamonds you redeemed. We keep a history of your redemptions. Gift cards are delivered by Bitrefill (see Section 4.1).

Opinions, Views and Interests #

We collect comments, ratings, reviews, or feedback provided through our platform or social media. Feedback sent from the App is stored with your account ID. This information is used to facilitate community engagement, gather user feedback, improve our services, and enhance customer support interactions.

Information Collected from Third Parties #

We collect information from public sources, such as your public social media information; we may collect information about you directly from our distributors, sales representatives, suppliers, vendors or our third party processors who collect information on our behalf, such as authentication data from Google and Apple sign-in, purchase confirmations from the app stores and our subscription provider, and install attribution data from our measurement partner. This information is used to validate identity, improve service offerings, facilitate authentication processes, and measure our marketing.

Identity Verification #

In the event of a dispute only, such as a disputed redemption or a dispute over who owns an account, we may collect government-issued ID and selfie images to verify user identity, prevent fraud, comply with regulatory requirements, and enhance account security. This information is not collected during normal account creation or usage and is only requested and retained when necessary to resolve specific disputes.

3.2 How Information May be Used #

We process your personal information for the following purposes, depending on the specific context:

Account Creation and Authentication: We process personal and authentication information (including authentication data from third-party services) to create and manage user accounts.
Service Provision and Customer Support: We use personal, device, and usage details to provide and improve our services, run missions and rewards, personalize content, respond to user inquiries, offer customer support, and ensure platform security.
Security and Fraud Prevention: We process device details, IP addresses and usage logs to prevent unauthorized access, protect against account hacking, detect and prevent fraud, ensure security, and comply with legal obligations.
Redemption: We use your date of birth, country, redemption history and account activity to check that you are eligible to redeem, to apply redemption limits, and to detect fraud. These checks can automatically stop a redemption.
Chat Safety and Moderation: We filter chat messages automatically, review reported messages and profiles, and act on accounts that break our Community Standards. If we find content that appears to involve the sexual exploitation of a child, we report it to the National Center for Missing & Exploited Children (NCMEC) as U.S. law requires, and we may share information with law enforcement.
Advertising and Measurement: We show optional rewarded ads through ad partners, which receive your advertising identifier, and we measure installs and campaign performance. On iOS, ad partners only receive the IDFA if you allow tracking when the App asks.
Marketing and Communications: We collect opinions, interests, and usage details to send personalized content and promotional materials, subject to user consent. You can turn notification categories off in the App under Settings, Notifications.
Website Operations and IT Management: We collect device and usage details to operate, maintain, and improve our website, as well as manage IT security and conduct audits.
Safety and Legal Compliance: We process personal information to maintain the safety, security, and integrity of our website, products, databases, and services, as well as comply with applicable legal obligations.
Analytics and Market Research: We analyze usage details, device information, and pseudonymized data to assess market trends, optimize our offerings, and enhance user experience.
Surveys and Feedback: We collect responses, opinions, and reviews from users to understand customer satisfaction and improve our services and products.

4.1 Disclosure of Your Information #

We do not sell or rent your personal information, and we do not share it with third parties for their own direct marketing purposes without your explicit consent. We share your advertising identifier with ad partners to show ads, which some U.S. state laws treat as "sharing" (see Section 12). We may share your personal information only when necessary to provide the core functionality of Petoskey and its third-party features.

We may disclose aggregated information about our users, fully anonymized usage details, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this Privacy Policy:

To our affiliates.
To our trusted contractors and service providers we use to support necessary business operations (such as cloud hosting, security services, and customer support), based on our instructions and in compliance with our Privacy Policy and appropriate confidentiality and security measures. They are listed below with the information each receives.
To our sales representatives for the purpose of fulfilling your requests and selling our services.
To a buyer or other successor in the event of, or pursuant to negotiations in connection with, a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Petoskey's assets.
With your consent.
To comply with any court order, law, or legal process, including investigation of potential violations and to respond to any government or regulatory request, and to report suspected child sexual exploitation to NCMEC.
To detect, prevent or otherwise address fraud, security or technical issues.
To enforce or apply our Terms of Use chubkins.app/terms and other agreements, including for billing and collection purposes.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Petoskey, our customers, or others.
For any other purpose disclosed by us when you provide the information.

Our Service Providers #

We share personal information with these types of service providers, only as needed for the purposes in this Privacy Policy:

App stores, to process purchases and subscriptions, and to let you sign in with Apple or Google.
Subscription management, to keep track of your subscription.
Cloud hosting and storage, for our servers, databases, chat and photos.
Analytics and crash reporting, including the platform that runs our missions and rewards, to operate the game and fix problems.
Push notification services, to deliver notifications, including chat message previews.
Advertising and measurement partners, to show ads and measure installs and campaigns.
Our gift card partner, to deliver redeemed gift cards to your email address. When you use a code on the partner's website, its own privacy policy applies.
A location lookup service, to find your country from your IP address.
Our internal communication tools, where our team reviews reported chats.

We require the service providers, analytics tools, advertising networks, SDKs and affiliates that receive personal information to protect it to the same or an equal standard as this Privacy Policy. Where they process personal information on our behalf, they are bound by contract to (i) process it only on our written instructions and (ii) keep it confidential and secure, together with any other requirements of applicable law.

4.2 Data Security and Data Breach #

We take appropriate technical and organizational measures to ensure the security of your personal data, including encryption in transit, access controls, and regular security assessments.

In the event of a data breach involving personal information, we will:

Assess the scope and impact of the breach.
Notify affected users within timing windows required by law.
Report the breach to the relevant data protection authority when applicable.
Take corrective measures to prevent future occurrences.

If you suspect unauthorized access to your data, please contact us immediately at privacy@chubkins.app.

5. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION #

Because of the international nature of our business, we may need to transfer your personal information to third parties as noted above (subject to binding contractual obligations, also considered "standard contractual clauses" where required by applicable law), solely in connection with the purposes set out in this policy.

For this reason, we may transfer your personal information to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located. Our servers, databases and chat are hosted in Canada, and some files, including profile photos, are stored in the United States. Our service providers process data in the United States and other countries where they operate, and gift card deliveries are processed in Sweden.

6. LINKS TO THIRD PARTY WEBSITES #

The App and our website may also contain links to websites operated by other companies, including websites operated by our third-party service providers and distributors, and unrelated third parties. This Privacy Policy does not apply to personal information collected on any of these other websites.

When you access third-party websites through a link in the App or on our website, please review the Privacy Policy posted on that website.

We obtain explicit consent for non-essential cookies and provide users with options to manage their preferences through our cookie management panel. For more details, please refer to our Cookie Policy.

We may collect information through the use of "cookies," tracking pixels, and similar technologies. Cookies are small text files created by websites and stored on your device. They provide a way for us to recognize you and keep track of your settings and preferences.

We use cookies and similar technologies to provide you with a secure experience and to understand, among other things, how you navigate our website, learn what content is popular, recognize repeat users, and save your account information.

Our website is not configured to read or respond to "do not track" settings or signals in your browser settings. We do honor Global Privacy Control signals as a request to opt out of sale or sharing (see Section 12). When you visit our website for the first time, we will show you a pop-up with an explanation about cookies. You do have the right to opt-out, manage and object to the further use of non-functional cookies through our cookie panel.

You can also disable the use of cookies via your browser, but please note that our website may no longer work properly.

8. CHANGES TO THIS PRIVACY POLICY #

Petoskey Gaming Company, LLC may update or modify this Privacy Policy from time to time at its discretion, and reviews it at least once every 12 months. When changes are made, we will post the updated version here and revise the "Last updated" date at the top of the page.

Unless otherwise specified, the updated Policy will apply to all information we hold about you and your account. We encourage you to review this Policy periodically to stay informed about how we protect your information.

We may also notify you of material changes through the App, by email, or through other appropriate means. Your continued use of Chubkins after any changes take effect constitutes your acceptance of the updated Privacy Policy. If you do not agree to the updated terms, you should stop using the App.

9. YOUR RIGHTS AND CHOICES #

We want to make sure your information is accurate and up to date. Depending on where you live, you may have the right to:

Access: ask for a copy of the personal information we hold about you.
Correction: ask us to correct information that is inaccurate or incomplete.
Deletion: ask us to delete your personal information (see Section 10).
Portability: ask for your information in a structured, commonly used, machine-readable format.
Objection and withdrawal of consent: object to some uses of your information, and withdraw consent you gave earlier, such as to marketing notifications or ad tracking.

You can turn notification categories off in the App under Settings, Notifications. You can limit ad tracking in your device settings, and on iOS by declining the tracking prompt or changing it later in Settings.

To make a request, write to privacy@chubkins.app. We will verify your identity before acting on a request, usually by confirming that you control the email address or sign-in on the account, and we will respond within the time required by applicable law. We will not treat you differently for exercising any of these rights.

10. DELETING YOUR ACCOUNT #

You can ask us to delete your account in any of these ways:

In the App: open Settings and tap Delete Account. This deletes your account right away.
With the Player Data Deletion Request form: https://forms.gle/PZffvJ9ykWYi2S5XA
By email: write to privacy@chubkins.app from the email address on your account, or include your Player Share Code.

We process requests made through the form or by email within 30 days.

When your account is deleted, we remove your email address, your Google and Apple sign-in links, your device identifiers, IP address and push notification token, and your profile photo. Your display name becomes "Deleted User", and we keep only the year of your date of birth. Open invites are cancelled, and any Chubkin you co-parent stays with your co-parent.

We keep some records after deletion, without your name, email or device identifiers: purchase, subscription and redemption records, for tax, accounting and fraud prevention; server logs and gameplay records; and any report made to NCMEC, as the law requires. Chat messages are deleted as described in Section 11. These records are kept for the periods in Section 11.

Deleting your account does not cancel a Care Pass subscription. Cancel it in your App Store or Google Play subscriptions first.

11. DATA RETENTION #

We keep personal information only as long as we need it for the purposes in this Privacy Policy:

Account and profile data: while your account is active. When you delete your account, it is deleted or de-identified as described in Section 10.
Gameplay and analytics data: up to 5 years from collection, to run and balance the game economy and improve the App.
Purchase, subscription and redemption records: up to 5 years, for tax, accounting and fraud prevention.
Fraud prevention data, such as IP addresses and device identifiers linked to suspected fraud: up to 5 years.
Chat messages and photos: up to 12 months, then deleted. Chat backups are kept for 30 days.
Reported chat messages: until the report is resolved. If we report content to NCMEC, we keep the report and the related account data for 1 year after the report, as U.S. law requires.
Identity verification images: deleted after the dispute is resolved (see Section 3.1).
Crash data: as long as Firebase Crashlytics keeps it, currently 90 days.
Server logs: 28 days.
Date of birth: the year of birth only, after your account is deleted.

12. ADDITIONAL INFORMATION FOR U.S. STATE RESIDENTS #

If you live in California or another U.S. state with a consumer privacy law, you have the rights in Section 9, and the following also applies.

Categories we collected in the last 12 months: identifiers (such as account ID, email address, IP address and device and advertising identifiers); commercial information (purchases, subscriptions and redemptions); internet or other electronic network activity (gameplay, usage and crash data); approximate geolocation (country); audio, electronic or visual information (profile and chat photos); the content of chat messages; your date of birth, if you redeem; and inferences used to tailor missions and offers. Section 3.1 explains where each comes from, Section 3.2 why we use it, and Section 4.1 who receives it.

Sale and sharing: we do not sell personal information for money. Sending your advertising identifier and device details to our ad partners to show ads can count as "sharing" for cross-context behavioral advertising, or as a "sale" under some state laws. You can opt out with the "Do Not Sell or Share My Personal Information" link on our website, by writing to privacy@chubkins.app, by limiting ad tracking on your device, or by sending a Global Privacy Control signal. We do not knowingly sell or share the personal information of anyone under 16.

Sensitive information: we use your date of birth only to check that you are old enough to redeem, and the content of your chat messages only to deliver and moderate chat. We do not use sensitive personal information to infer characteristics about you.

Requests: you can make a request by writing to privacy@chubkins.app or, for deletion, by using the form in Section 10. An authorized agent can make a request for you with your signed permission, and we may ask you to confirm your identity with us directly. If we decline your request, you may appeal by replying to our decision.

13. CONTACT US #

For privacy questions and requests, including deletion: privacy@chubkins.app. For everything else: support@chubkins.app.

Petoskey Gaming Company, LLC